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Previous sales of comparables

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Dave Disselhorst

Freshman Member
Joined
Apr 21, 2002
Professional Status
Certified Residential Appraiser
State
Illinois
I just want to check on something a friend told me. He stated Illinois has a supplemental standard requiring reporting on previous sales of comparables is 36 months not 12 months. I looked up in the ILCS code under Business Practices and found nothing related to this suppelemental standard.
 
This is from our Administrative Rules. Technically, with the NEW USPAP, Supplemental Standards went bye-bye but you still must comply with regulations.

Pursuant to Section 15-10(a) of the Act, failure to comply with any of the following shall be considered a violation and may be subject to discipline as provided for in the Act and this Part:

a) In developing a real property appraisal, an appraiser shall analyze any prior sales of the property that occurred within three years if such information is readily available to the appraiser in the normal course of business. In developing a real property appraisal of one to four units of residential property, an appraiser shall analyze any prior listings of the property that occurred within three years if such information is readily available to the appraiser in the normal course of business.

From the NEW USPAP:
SUPPLEMENTAL STANDARDS RULE: The SUPPLEMENTAL STANDARDS RULE was deleted because the other requirements of USPAP eliminate the need for the Rule.

The duty for the appraiser to comply with applicable assignment conditions is embedded in the obligations to provide ethical and competent services. The SCOPE OF WORK RULE requires appraisers to identify the problem to be solved, which includes identification of assignment conditions. In communicating assignment results, the requirement that reports be meaningful and not misleading creates an obligation to comply with applicable laws, regulations, and guidelines.
 
Brian

Thanks for the reply and I agree. I received a condition from an underwriter regarding analyzing prior listings or sales of comparables within 12 months. I told them I checked the box indicating I did analyze the listing/sales within the past 12 months and found no indication through MLS or public records. My friend stated I needed to go back 36 months of listing/sales of comparables. I know there is a requirement for subject. Does the requirement also apply for comparables? I routinely check back farther and list any if I see them anyway.
 
This brings me back to an AI class I took and this Illinois rule/topic came up. LOL. Half the class said the 36 month sales history applies only to the subject property while the other half argued it was for both the subject and comparable properties.
 
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It is my opinion, if the information is available, that you report the last sale of the property no matter how long ago it was.

This goes for the subject and the comparable properties.

Step up to the next level, don't just meet the minimum standards of reporting.
 
I was at an AI meeting as well, where half the room said 12 for comparables, half said 36. The instructor said it was really 12, as there was always "talk" about requiring 36, but it never went into effect. Not sure what the heck THAT was all about, not even sure if any of that info is correct! I was taught to search them all 36, so I always have.
 
If reporting on a Fannie ......... the minimum requirements are PRE-PRINTED......... and specifically stated in their appraisal requirements on the website


36 /SUBJECT 12 /COMPS. :icon_idea: :) { see first Bold Para below }


XI, 203: Appraisal and Property Inspection Report Forms (11/01/05)
Our appraisal report forms recognize the Uniform Standards of Professional Appraisal Practice as the minimum appraisal standards for the appraisal industry.

In addition, we have established our own separate appraisal requirements to supplement the Uniform Standards because we believe that this is necessary to ensure that all of our specific concerns are addressed for any given appraisal.

Our appraisal report forms are designed in a way that results in an appraiser’s being in full compliance with our requirements if he or she provides all of the information required by the forms and presents the applicable data accurately and completely.

Our appraisal report forms provide a concise format for presenting both the appraiser’s description of the subject property and the valuation analysis that leads to the opinion of market value. We have one appraisal report form for reporting an appraisal for each property and inspection type for both Desktop Underwriter and manually processed mortgages. The appraisal report form that should be used generally depends on the type of property and property inspection required. The appraiser must complete our forms in a way that will clearly reflect the thoroughness of his or her investigation and analysis and provide the rationale for the opinion of market value.

Although the scope of work for the appraisal or the extent of the appraisal process is guided by our appraisal report forms, the forms do not limit or control the appraisal process. The appraiser’s analysis should go beyond any limitations of the forms, with additional comments and exhibits being used if they are needed to adequately describe the subject property, document the analysis and valuation process, or support the appraiser’s conclusions.

The extent of the appraiser’s data collection, analysis, and reporting must be determined by the complexity of the appraisal assignment.

For example, the scope of work for an appraisal based on an interior and exterior property inspection reported on the Uniform Residential Appraisal Report (Form 1004) is based on the complexity of the appraisal assignment and the reporting requirements of the appraisal report form, including the stated definition of market value, statement of assumptions and limiting conditions, and certifications. The appraiser is required, at a minimum, to:

perform a complete visual inspection of the interior and exterior areas of the subject property,
inspect the neighborhood,
inspect each of the comparable sales, at least from the street,
research, verify, and analyze data from reliable public and/or private sources, and
report his or her analysis, opinions, and conclusions in the appraisal report.

The stated scope of work on the appraisal report forms reflect the minimum level of research and analysis required. The appraiser can expand the minimum scope of work for the appraisal and report on any additional research or analysis that was necessary and performed based on the complexity of the appraisal assignment. The need for an expanded scope of work is specific to the particular appraisal assignment and should be the exception, not the norm, for appraisals on typical one-unit properties.
 
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Could not find any information in a publication or Illinois Office of Banks and Real Estate website.
 
In Illinois, a 36-month sales history of the Subject property is required.

Also required for an appraisal of a 2-4 unit property:
"an appraiser shall analyze any prior listings of the property that occured within three years if such information was readily available..." (Illinois' "The R.E. Appraiser Rules of 2002", Sec. 1455.250).
"Prior listings" is not limited to "for sale"; remember, "...ANY prior listings..."

Prior to enactment of the "Rules", there WAS discussion of expanding the requirements to include a 36-month sales history for the sold comparisons, but this was not enacted. That stated, I believe that it is GOOD practice to include any known prior transfers of the sold comparisons, even if such is limited to an "fyi" (as an old sale etc.).
 
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